June 20, 2019
Office of Management and Budget
9257 New Executive Office Building
725 17th Street NW
Washington, DC 20006
RE: Request for Comment on the Consumer Inflation Measures Produced by Federal Statistical Agencies (Directive No. 14)
Dear Ms. Potok:
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Office of Management and Budget related to its request for comment on the, "Consumer Inflation Measures Produced by Federal Statistical Agencies (Directive No. 14)," published in the Federal Register originally on May 7, 2019. Representing over 104,000 registered dietitian nutritionists (RDNs);1 nutrition and dietetic technicians, registered (NDTRs); and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation's health through food and nutrition.
The Academy urges OMB to consider how each consumer price index under review would impact the eligibility criteria for individuals and families seeking assistance from programs that help promote positive health outcomes such as federal nutrition programs.
A. Academy Position on Food Insecurity
The Academy is committed to improving the health of Americans by ensuring access to a nourishing, safe and affordable food supply. The dietetics practitioner and nutrition educators consider the health, safety and welfare of the public at all times. The Academy's guiding principle is our commitment to improving health for all, especially those most susceptible to food insecurity. It is the position of the Academy that systematic and sustained action is needed to achieve food and nutrition security in the United States. To achieve food security, effective interventions are needed, along with adequate funding for, and increased utilization of, food and nutrition assistance programs.2
B. Participation in Federal Nutrition Programs Improves Food Security and Health Outcomes
Food insecurity significantly impacts the health and well-being of individuals and is a risk factor for negative psychological and health outcomes.3 It also increases the prevalence and severity of diet-related disease, such as obesity, type 2 diabetes, heart disease, stroke and some cancers.4,5,6 Research shows that SNAP is effective at reducing food insecurity.7,8,9 According to one estimate, SNAP reduces food insecurity by approximately 30 percent10 and nearly one in eight American households experience food insecurity during the year.11
Similarly the WIC program in an effective and cost savings federal nutrition program. A study from the Robert Wood Johnson Foundation examined the impact of the WIC food package and its impact on a child's diet and found that not only was there a significant decrease in overall obesity rates for children age zero to four (six percent), but there also was an increase in breastfeeding rates, which lead to healthier mothers and babies.12
In a 2017 study conducted with approximately 500,000 Californians, WIC resulted in cost-savings of about $349 million and the prevention of 7,575 preterm births; spending $1 on prenatal WIC resulted in mean savings of $2.48.13
Close to 30 million children a day depend on the National School Lunch and Breakfast Programs and nearly 75% of them come from low-income households, which means they are relying on a free or reduced-priced meal. According to the School Nutrition and Meal Cost study, the changes to the school meal nutrition standards significantly increased the dietary quality of both the lunch and breakfast program offerings.14 Access to meals of high nutritional value position children to have positive health and academic outcomes.
The Academy is concerned that adjustments to the inflation index that may impact the poverty threshold used to calculate program eligibility and therefore reduce the number of individuals and families accessing critical nutrition programs could have long and short term negative health implications.
C. Considerations for Price Index Reviews
The Academy urges OMB to review the recent evidence that suggests that a slower rising index, like the Chained CPI, may not be an accurate reflection of price increases for low income households. For example, some research shows that prices have been rising faster than the CPI-U (which the Census Bureau currently uses) for expenses that make up the majority of low income households' spending and that these basic necessities make up a larger portion of their budget than higher income households.15,16,17 Additionally, those living in low income households may have limited access to retailers in their communities, transportation barriers and limited online access. These challenges may make it more difficult to adjust spending to price changes.18,19,20
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the Office of Management and Budget related to its request for comment on the, "Consumer Inflation Measures Produced by Federal Statistical Agencies (Directive No. 14)." We urge OMB to carefully consider which consumer price index is most appropriate for low income households and the potential health implications associated with changes to the current poverty threshold used to calculate eligibility for federal health and nutrition programs. The research suggests using one with the slowest rising index is not suitable for this population. Please contact either Jeanne Blankenship at 312/899-1730 or by email at email@example.com or Liz Campbell at 202-775/8277, ext. 6021 or by email at firstname.lastname@example.org with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Liz Campbell, MA, RD
Legislative & Government Affairs
Academy of Nutrition and Dietetics
1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation’s food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.
2 Holben, D. (2010). Position of the American Dietetic Association: Food Insecurity in the United States. Journal of the American Dietetic Association. 110(9), 1368-1377.
3 Hartline-Grafton, H. (2017). The Impact of Poverty, Food Insecurity, & Poor Nutrition on Health and Well-Being. Washington, DC: Food Research & Action Center.
4 Franklin B. Jones, A., Love, D., Puckett, S., Macklin, J., & White-Means, S. (2012). Exploring mediators of food insecurity and obesity: a review of recent literature. Journal of Community Health. 37(1), 253-264.
5 Berkowitz, S., A., Karter, A., J., Corbie-Smith, G., Seligman, H. K., Ackroyd, S. A., Barnard, L. S., Atlas, S. J., & Wexler, D. J. (2018). Food insecurity, food "deserts," and glycemic control in patients with diabetes: a longitudinal analysis. Diabetes Care, 19, 171981.
6 Gregory, C., A., & Coleman-Jensen, A. (2017). Food insecurity, chronic disease and health among working-age adults. Economic Research Report, 235. Washington, DC: U.S. Department of Agriculture, Economic Research Service.
7 Mabli, J., & Worthington, J. (2014). Supplemental Nutrition Assistance Program participation and child food security. Pediatrics, 133(4), 1-10.
8 Ratcliffe, C., McKernan, S. M., & Zhang, S. (2011). How much does the Supplemental Nutrition Assistance Program reduce food insecurity? American Journal of Agricultural Economics, 93(4), 1082-1098.
9 Nord, M. (2012). How much does the Supplemental Nutrition Assistance Program alleviate food insecurity? Evidence from recent programme leavers. Public Health Nutrition, 15(5), 811-817.
10 Ratcliffe, C., McKernan, S. M., & Zhang, S. (2011). How much does the Supplemental Nutrition Assistance Program reduce food insecurity? American Journal of Agricultural Economics, 93(4), 1082-1098.
11 Coleman-Jensen, A., Rabbit, M. P., Gregory, C. A. & Singh, A. (2018). Household food insecurity in the United States in 2017. Economic Research Service Report, 256, Washington, DC: U.S. Department of Agriculture, Economic Research Service.
12 Chiasson, MA, Findley, SE, Sekhobo, JP, Scheinmann, R, Edmunds, LS, Faly, AS and McLeod, NJ Changing WIC changes what children eat. Obesity, 2013;21: 1423–1429. doi: 10.1002/oby.20295.
13 Niango et al. Economic evaluation of California prenatal participation in the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) to prevent preterm birth. Preventive Medicine.
14 USDA. School Nutrition and Meal Cost Study. Accessed on June 8, 2019.
15 Price changes for housing made up 42 percent of the overall CPI-U in December 2018; rent of one's primary residence made up 8 percent.
16 Jonathan Church, "The cost of 'basic necessities' has risen slightly more than inflation over the last 30 years," Beyond the Numbers: Prices and Spending, Vol. 4, No. 10, June 2015.
17 Federal Reserve Bank of Chicago, "IBEX Inflation," June 23, 2015, and CBPP calculations. Calculations reflect households ranked by size-adjusted income and inflation rates compounded over time.
18 Greg Kaplan and Sam Schulhofer-Wohl, "Inflation at the Household Level," Journal of Monetary Economics, 2017, Figures are for the third quarter of each year. The differences between lower- and higher-income groups in other quarters are similar or even larger.
19 David Argente and Munseob Lee, "Cost of Living Inequality during the Great Recession," Kilts Center for Marketing at University of Chicago Booth School of Business, Nielsen datasets Joint Paper Series, March 1, 2017.
20 Benjamin Faber and Thibault Fally, "Firm Heterogeneity in Consumption Baskets: Evidence from Home and Store Scanner Data," National Bureau of Economic Research Working Paper No. 23101, August 2017.